Tax Litigation

Cooley's Tax Litigation practice is recognized as one of the premier tax litigation practices in the country, with a reputation for innovative and effective resolution of significant federal, state and international tax controversies, including numerous landmark tax cases. We regularly litigate in the United States Tax Court, United States Court of Federal Claims and other federal and state jurisdictions; handle tax appeals in the United States Circuit Courts of Appeal; and represent taxpayers in all aspects of Internal Revenue Service and state examinations and administrative appeals.

Our Tax Litigation practice consists of seasoned tax lawyers, recognized as leaders in tax law, with extensive trial experience in all tax forums. Our lawyers are recognized as the best in the United States by Chambers USA, Euromoney, and Who's Who Legal, have prior experience in the Internal Revenue Service and U.S. Treasury Department, and teach graduate tax courses, including at the New York University School of Law. Further, in 2011, the firm was named "U.S. Tax Court Firm of the Year" by the International Tax Review for its work on Entergy Corporation v. Commissioner case in the U.S. Tax Court.

We combine our extensive knowledge of IRS procedure, customs, practice, and authority with in-house and litigation resources to create an effective, efficient team. We provide focused guidance to our clients early in the tax controversy process to protect their litigating position while taking advantage of the procedural alternatives available. While we have been successful resolving cases administratively, we are ready to litigate, and often do, when in our client's best interests.

Key Facts

  • We have handled landmark, precedent-setting tax cases, including:
    • Overturning Treasury Regulations adverse to our client
    • Establishing taxpayer-favorable precedent
    • Establishing new procedural protections of our clients' rights
    • Obtaining industry-wide resolution of common issues
  • Cooley's clients have over $10 billion in controversy in current cases
  • Our current Tax Litigation practice attorneys:
    • Were counsel in over 80 decided cases
    • Have filed more than 200 cases in court
    • Have represented clients in hundreds of administrative tax cases

Related Practices


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